The format of the SQF Code, Edition 8 has been updated to provide customized requirements for key industry sectors in separate stand alone codes.
All food safety codes will be submitted to the Global Food Safety Initiative (GFSI) for the benchmarking of all industry scopes that have GFSI requirements.
There will be no significant changes to the codes. However, due to the addition of new elements (or the elimination or consolidation of elements) there are some minor numbering changes.
The SQF Code Edition 8 replaces the SQF Code Edition 7, and is valid for all certification audits conducted after January 2, 2018. Those sites with an existing SQF certification will be required to upgrade their processes and procedures to meet the requirements outlined in Edition 8 by that date.

I noticed a, seemingly, repetitive illogicality in most of the SQF8 Safety Codes (but, perhaps strangely, not all). For example the Manufacturing Code has -

2.7.2 Food Fraud

2.7.2.1 The methods, responsibility and criteria for identifying the site's vulnerability to food fraud shall be documented, implemented and maintained. The food fraud vulnerability assessment shall include the site's susceptibility to product substitution, mislabeling, dilution, counterfeiting or stolen goods which may adversely impact food safety.

But in the glossary –

Food Fraud

As defined by Michigan State University, a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain.

(same def. as GFSI ?)

I think the difficulty is that Fraud defs. typically (inc.BRC) use defs (eg economic...) which are not safety-oriented but "could" "incidentally" overlap/generate safety-related events. (This is to ditinguish between "threats" which are categotically safety motivated". But SQF8 Food Safety Codes must be exclusively safety-related.

It is possible the “safety” wording of 2.7.2 will exclude many GFSI designated vulnerability/fraud exploits.

As would be expected, the SQF8 Quality Code textually has “safety” replaced by “quality” so no direct textual “clash”. (ignoring SQF's own choice of “quality” to be interpreted as non-safety).

? This SQF "Level" division represents a promotional advantage over BRC7 (the latter wants all fraud scenarios to be auto-covered) ?

The new GFSI Issue 7 Guidance Document was published just this week and addressing Food Fraud is required. It is not optional. There is no debate on “if” it is included. With the requirements just being finalized the expanded questions of “how” to comply will be for the future

GFSI 7
Food fraud mitigation plan The standard shall require that the organisation has a documented plan in place that specifies the measures the organisation has implemented to mitigate the public health risks from the identified food fraud vulnerabilities.

An example would be Melamine in the Chinese Milk Scandal which was added for economic gain but created one of the largest 'food safety events':

The format of the SQF Code, Edition 8 has been updated to provide customized requirements for key industry sectors in separate stand alone codes.
All food safety codes will be submitted to the Global Food Safety Initiative (GFSI) for the benchmarking of all industry scopes that have GFSI requirements.
There will be no significant changes to the codes. However, due to the addition of new elements (or the elimination or consolidation of elements) there are some minor numbering changes.
The SQF Code Edition 8 replaces the SQF Code Edition 7, and is valid for all certification audits conducted after January 2, 2018. Those sites with an existing SQF certification will be required to upgrade their processes and procedures to meet the requirements outlined in Edition 8 by that date.

The reality is that the terminologies involved/selected by GFSI were always going to be a semantic fudge (predictable from the position paper of 2014). Just as an example from "their" website -

Clearly the most common and dangerous public health threat is from adulteration, but all types of Food Fraud include vulnerability. While the horsemeat adulteration did not result in a public health incident, it could have… and we would have had no way to trace the dangerous products. Even stolen genuine goods (could?) pose a public health vulnerability since we lose sight of the product as it moves through the supply chain. The product could have spoiled from mishandling, or that lack of transparency would provide a fraud opportunity for other types of actions.

If yr GFSI-7 quotation is complete (I haven't read the Standard), it is surely mis-matched to the definition in the SQF8 Glossary. If SQF/GFSI are content to disregard the latter then i agree with you that there is no significant textual difference at all for Codes where SQF includes fraud in the text. I deduce that for GFSI/SQF8 all food fraud events which do/did not involve safety, eg Horsegate, will be outside the scope of, for example, the Manufacturing Code. Very Good News for relevant SQF Users !.

Just for comparison, Here is the (prematurely?) quoted BRC definition for GFSI-7 :

The Global Standard for Food Safety Issue 7 defines food fraud as the fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain, by either increasing the apparent value of the product or by reducing the cost of its production.

Safety-related aspects are apparently inconsequential to BRC as implied in their Glossary definition (similar to SQF8's). BRC want the lot for Due Diligence.

IMO SQF8'ers have a potential benefit except will maybe now need a differential Fraud database.

I deduce that for GFSI/SQF8 all food fraud events which do/did not involve safety, eg Horsegate, will be outside the scope of, for example, the Manufacturing Code. Very Good News for relevant SQF Users !.

Just to put a fine point on the Food Fraud issue with SQF: if the issue has the potential to be a food safety risk (ex. melamine added to a commodity to increase protein content when the product is analyzed)it falls under Level 2 (in Ed. 7.2) or whichever Food Safety Code you fall into in Ed.8. If the issue is food fraud for monetary gain, but presents no food safety risk (ex. extra virgin olive oil cut with cheaper oils) it would fall under Level 3 (in Ed. 7.2) or the Food Quality Code in Ed.8.

Just to put a fine point on the Food Fraud issue with SQF: if the issue has the potential to be a food safety risk (ex. melamine added to a commodity to increase protein content when the product is analyzed)it falls under Level 2 (in Ed. 7.2) or whichever Food Safety Code you fall into in Ed.8. If the issue is food fraud for monetary gain, but presents no food safety risk (ex. extra virgin olive oil cut with cheaper oils) it would fall under Level 3 (in Ed. 7.2) or the Food Quality Code in Ed.8.

Afaik "Food Fraud", per se, is not mentioned in SQF Code 7.2. Also neither in Codex or NACMCF which are the SQF referenced sources for safety (ie haccp).

But presumably there is no argument that much(all?) of the product involved in the melamine episode failed Product Specifications regarding adulterants.

With respect to SQF8, I think you are agreeing with the comments in Post 11.

If so, I predict that SQF are about to become (negatively ) out of step with GFSI as far as their Manufacturing Code is concerned (I haven't attempted a precise comparison with GFSI's ["safety"] definition of Food Fraud but i anticipate this will include all "species" of Food Fraud, eg as interpreted in BRC). Reasons for the out-of-step are given in post 11.

(BRC avoid a conflict since they fortuitously blend both quality(non-safety) and safety factors into one (nominal) Food Safety Standard).

You're correct about food fraud specifically being called out in Ed. 7.2 (although I'd guess that an overzealous auditor might lump it in with 2.4.5 - Incoming Goods and Services).

Re. melamine I was referring to the addition of melamine in China to increase the apparent protein content in powdered baby formula. From a Reuters article:

"WHY ADD MELAMINE TO MILK POWDER? -- Melamine is rich in nitrogen, and relatively cheap. Adding it to sub-standard or watered-down milk makes the milk's protein level appear higher. Standard quality tests estimate protein levels by measuring nitrogen content. IS THIS WHY IT WAS ADDED TO PET FOOD? -- Yes. Melamine was linked to the deaths of cats and dogs in the United States last year after it was added to wheat gluten and other pet food ingredients exported from China, in another attempt to boost the products' apparent protein content."

Re. melamine I was referring to the addition of melamine in China to increase the apparent protein content in powdered baby formula. From a Reuters article:

"WHY ADD MELAMINE TO MILK POWDER? -- Melamine is rich in nitrogen, and relatively cheap. Adding it to sub-standard or watered-down milk makes the milk's protein level appear higher. Standard quality tests estimate protein levels by measuring nitrogen content. IS THIS WHY IT WAS ADDED TO PET FOOD? -- Yes. Melamine was linked to the deaths of cats and dogs in the United States last year after it was added to wheat gluten and other pet food ingredients exported from China, in another attempt to boost the products' apparent protein content."

You are mixing up two incidents in your post, the first I already posted about in post 7

The pet food incident was similar but not the same as it was related to gluten not milk.

JFI regarding my speculations over SQF8/food fraud in previous posts, i just ( ) noticed this statement in the SQF8 FAQ -

45. Is food fraud only for food safety related issues?

Food fraud is covered in both the Food Safety and Quality Codes. In the SQF Food Safety Codes it covers only food fraud that may impact food safety. The SQF Quality Code includes all food fraud issues.

Interests:We specialize in helping small to mid-sized food companies to develop & implement SQF Systems to achieve certification in a relatively short period of time. Our operational area includes the Unites States, Costa Rica, Panama and the Caribbean.

Posted 15 July 2017 - 04:27 AM

Hmmmm is right. We found several fascinating items in the new 8.0 that we reported to SQFI.

On the note of Edition 8 having problems, I actually spent two days going through and comparing, side-by-side, Modules 3, 4 and 11 (which, due to our particular product and process, we have to meet the requirements of all three modules). I found a LOT of issues...many inconsistencies, most of which are rather inane and it looks like there wasn't much work done to attempt to harmonize the three together, which creates a big headache for those of us who have to meet requirements of more than one Module.

Understandably, some of the items within each module would be different, but there are actually VERY few true differences from what I can tell...wouldn't it be much easier to simply produce one Manufacturing module, and include all of the combined elements of all three Modules, and then just make note of the very few that don't apply to specific forms of manufacturing (such as animal feed, pet food, or food production)? On a grand scale, there are really only substantial differences in the areas of Mixing, Formulation, Medication/Medicine. The rest are trivial differences at best, and could easily be included as requirements for all Manufacturing without creating undue additional requirements on any one Module segment.

I have added the attachment for your perusal, if you are so inclined - I simply put all text in red that was inconsistent (including code numbers)...do you think this would be worth sending to someone at SQF so they could, perhaps, try to align things better?

Interests:We specialize in helping small to mid-sized food companies to develop & implement SQF Systems to achieve certification in a relatively short period of time. Our operational area includes the Unites States, Costa Rica, Panama and the Caribbean.

Posted 01 August 2017 - 10:29 PM

Most certainly call SQFI.

When we found issues with the new 8.0 we called, reported them and they followed up.

The SQFI staff has been fantastic thru the years in being proactive on inputs and suggestions.

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